IMCA Publishes Revisions of Two Important Diving Guidance Documents

The International Marine Contractors Association (IMCA) has published revisions of two important diving publications – Diving Equipment Systems Inspection Guidance Note (DESIGN) for Mobile/Portable Surface Supplied Systems (IMCA D 040 Rev 1) and Mobile/Portable/Daughtercraft Surface Supplied Systems (IMCA D 015 Rev 1). Both documents can be downloaded free of charge from the IMCA website, with printed copies available for purchase from the association.

“Our diving guidance documents are used throughout the world, indeed often use of them is a requirement for diving contractors responding to a tender,” explains Jane Bugler, IMCA’s Technical Director and Acting Chief Executive. “The DESIGN series of documents have long played an important role within the industry.

“In the early 1980s, in order to give some guidance to the offshore industry, IMCA’s predecessor the Association of Offshore Diving Contractors (AODC) started to produce a number of reference documents, standards and guidance notes. This process continued through the 1980s. It was clear, however, that there was still considerable confusion with some diving systems being ‘audited’ several times a year by different clients, each of whose representatives had slightly different interpretations as to what was required.

DESIGN’s long history
“AODC published document reference AODC 052 – Diving Equipment Systems Inspection Guidance Note (DESIGN) – in February 1989 that sought to clarify any interpretations necessary and to identify a common standard that could be applied by all parties during an inspection. It was intended for use offshore in the UK sector of the North Sea but in the absence of other guidance it became a standard reference in many parts of the world, particularly where there were no specific national regulations.

“Subsequently AODC expanded and revised the document which was re-issued as Rev. 1 in February 1995. This more comprehensive document covered both air and saturation diving systems. It was still based on the requirements of the UK sector of the North Sea but was adopted by many clients and diving contractors world-wide. Some users, however, found it to be complex and difficult to use.

“With the increasingly international nature of the offshore diving industry, IMCA revised AODC 052 Rev. 1 in order to simplify it, clarify any anomalies which had shown up and adapt it for international use, rather than restrict it to North Sea use. It was also decided to split it into separate documents, one for surface diving (IMCA D 023 published 2000) and the other for saturation diving (IMCA D 024 published 2001).

“Subsequently documents were issued in 2006 for surface supplied mixed gas diving (IMCA D 037) and mobile/portable surface supplied diving (IMCA D 040) and in 2014 for hyperbaric reception facilities (IMCA D 053). IMCA D 024 for saturation diving systems was revised and updated to Rev. 1 in 2013 and to Rev. 2 in 2014. IMCA D 023 was revised and updated to Rev. 1 in 2014. Our newly published guidance document is an adaptation of D 023 modified to specifically cover mobile/portable surface supplied diving equipment.”

Current Version of IMCA D 040

IMCA D 040 for mobile/portable surface supplied diving equipment has now been revised and updated to incorporate equipment improvements and changed operating practices since its first publication in 2006. In particular it has been enlarged to recognise the increased use of specially designed small vessels with the diving equipment permanently installed (daughtercraft) in addition to the simple versions of this type of equipment which are commonly referred to as ‘SCUBA-replacement’. The format has also been changed slightly to improve ease of use and provide better referencing.

It is intended that IMCA D 040 should be used in conjunction with IMCA D 018 – ‘Code of practice on the initial and periodic examination, testing and certification of diving plant and equipment’. Cross-references to this Code are provided where appropriate

The newly revised document offers examples of good practice. It gives advice on aspects of a diving system that should be configured in certain ways in order to provide a safer system of working. It also identifies how inspection and testing can be carried out safely and efficiently.

“IMCA D 040 has no direct legal status but many courts, in the absence of specific local regulations, would accept that a company carrying out diving operations in line with the recommendations of this document was using safe and accepted practices,” says Jane Bugler.

Printed copies are available from publications@imca-int.com at £10.00 for IMCA members and £20.00 for non-members. In addition to a comprehensive introduction and a list of acronyms, there are sections on The Competent Person; Responsibilities, Planned Maintenance Systems (PMS); Key features of the document; Completing the Document; and references, in addition to detail sheets on general safety; small vessel; control position; divers’ umbilicals; divers’ personal equipment; and high pressure air and gas storage.

IMCA D 015 Rev 1
A mobile/portable/daughtercraft surface supplied system, can, in certain circumstances, be used in place of a complete conventional surface supplied diving system where access for a full system is restricted or not possible.

Mobile/portable/daughtercraft systems vary considerably in their capabilities. At the simplest they comprise three cylinders of breathing air mounted in a frame with a small control panel and umbilicals which can be placed in an inflatable boat, typically to carry out a single dive, or may be used on a large barge or platform to allow diving from a location remote from the main diving area. This type of system is commonly referred to as SCUBA replacement and has the advantage of being readily portable, thus offering greater flexibility during the diving operation, but is limited in the supply of breathing air available.

At the other extreme they can be quite large, custom designed, daughtercraft with the ability to have two divers working in the water at the same time and to carry out several dives before needing to return to the mothercraft for replenishment.

When this technique is being used with diving from a small vessel (inflatable or larger daughtercraft) then there will always be a support vessel (known as the mothercraft) in the vicinity carrying all necessary extra diving support equipment and fitted with a suitable handling system for the safe launch and recovery of the small vessel. In some circumstances the support vessel may be replaced by a fixed installation carrying all the necessary extra diving support equipment and handling system.

“This guidance sets out what is generally regarded in the industry as good safe practice when diving using such equipment,” explains Jane Bugler. “The guidance is not mandatory and persons may adopt a different standard in a particular situation where to do so would maintain an equivalent level of safety. It is not intended that such equipment be used as a substitute for a complete surface supplied diving system, particularly if the full system can be safely accommodated at the diving location.”

Sections of IMCA D 015 Rev 1 deal with risk assessment, equipment requirements, depth limitation, minimum gas requirements, decompression facilities, medical equipment, testing and certification, divers’ umbilicals, diving personnel, diving from a small vessel, environmental considerations, and operational considerations. Printed copies are available from publications@imca-int.com at £5.00 for members and £10.00 for non-members.